Searching Content indexed under Tax Authorities by Bernie Pistillo ordered by Published Date Descending.
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Trump Administration Officials And Congressional Leaders Release "Unified Framework" For Tax Reform
Similar to a one-page plan previously released by the Trump administration back in April, the Framework sets forth a sweeping set of potential tax reform objectives but is lacking in substantive detail.
United States
5 Oct 2017
Latest Treasury Action On Inversions Upends Pending Transactions And Surprises Many For Its Broad Scope And Use Of Questionable Authority
On April 4, 2016, the Treasury Department and the Internal Revenue Service issued a sweeping package of new regulations intended to curtail inversion transactions
United States
27 Apr 2016
Proposed IRS Debt-Equity Regulations: Aimed At Post-Inversion "Earnings Stripping," But May Also Impact Ordinary Related-Party Debt
On April 4th, the IRS issued proposed regulations under Section 385 which could dramatically change how related-party indebtedness is treated for federal income tax purposes.
United States
18 Apr 2016
Private Ruling Endorses Taxpayer-Friendly Reading Of "Qualified Small Business" Under Section 1202
The IRS found that a company providing products and services primarily within the pharmaceutical industry was a "qualified trade or business" for purposes of Section 1202(e)(3).
United States
23 Sep 2014
Recently Proposed Treasury Regulations Regarding The Allocation Of Partnership Recourse And Nonrecourse Liabilities Contain Significant Changes For Many Routine Partnership Transactions
On January 29, 2014, the Internal Revenue Service and the Treasury Department issued proposed regulations modifying the rules under Section 752 regarding the allocation of recourse and nonrecourse partnership liabilities and clarifying some aspects of the disguised sale rules of Section 707.
United States
17 Feb 2014
Managing Offshore Holding Companies From China: Recent Case May Suggest Increased Tax Risk
As our readers know, foreign investments into the People’s Republic of China ("PRC") are typically structured through one or more holding companies domiciled in offshore jurisdictions.
4 Nov 2013
Favorable New Guidance On Eligibility Of Wind And Other Renewable Energy Facilities For The PTC Or The ITC In Notice 2013-60
On September 20, 2013, the Internal Revenue Service released Notice 2013-60, which significantly clarifies and expands the eligibility rules applicable to the investment tax credit and production tax credit for wind and certain2 other renewable energy facilities.
United States
30 Sep 2013
A Year-End Rush for the Exit? Tax Uncertainty and Transactional Planning in Q3/Q4 2012
A combination of pending actual and potential tax increases effective in 2013 may have a significant impact on transactional planning in the third and fourth quarters of 2012.
United States
15 Aug 2012
2011 Report Of Foreign Bank And Financial Accounts ("FBAR") Due June 30
We wanted to remind our clients that Treasury Form TD F-90 22.1 "Report of Foreign Bank and Financial Accounts" (commonly known as the "FBAR") is due on June 30, 2012 with respect to the calendar year 2011.
United States
20 Jun 2012
Reasserting Its Role As Final Interpreter Of The Law, The Supreme Court Rejects IRS "Fighting Regulation" In United States v. Home Concrete & Supply, LLC, Et Al.
On April 25, 2012, the Supreme Court issued a 5-4 opinion, written by Justice Breyer, concluding that Treasury Regulation § 301.6501(e)-1(a)(iii) was invalid.
United States
8 May 2012
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